Dr. David Duffy:

I thank the committee for inviting PII to attend. I am accompanied by Ivan Gaine and John Spain. PII is an independent and inclusive representative organisation for all sub-sectors of the Irish property industry and is part of IBEC. Membership of PII is open to all professional firms across the property industry, including home builders, contractors, private planning firms, architects, surveyors and engineers, legal professionals, property investors and financial institutions. In the delivery of new homes, home-builders face many challenges. The growth in input-cost inflation is impacting on viability and the new home pipeline. Financing is now a particular constraint. Interest rate rises have had a major impact. There are supports for owner-occupiers, but a critical challenge will be in the delivery of homes for rent. Uncertainty can also play a key role in home builders' decision making.

An efficient and effective planning system is essential to Ireland’s national interest and is key to delivering Ireland’s housing and infrastructure needs. The planning system must be robust enough to process the planning permission applications needed for a housing demand that could be as high as 50,000 to 60,000 homes per year in the near term. Delays or uncertainty in the planning process can directly impact the viability of new home delivery, either directly through planning applications or through approval applications for key infrastructure.

In 2022, PII made recommendations on overall planning reform and judicial review reform. There is too much uncertainty and a high level of risk in outcomes in the Irish planning system, especially when legal challenges are taken into consideration. This is making the funding and delivery of multi-unit developments and important infrastructure considerably more difficult, including energy and services. This position also poses a direct risk to Ireland’s attractiveness as a place to do business and for job creation. Without resolving our housing and planning challenges, Ireland’s international competitiveness is being undermined.

PII welcomes the review undertaken by the Government and the proposed Bill being discussed by this committee. The aim of bringing greater clarity and certainty to the overall planning system is very welcome. While many of the proposed changes are to be welcomed in themselves, more fundamental reform is needed to restore an effective planning system in which all participants can have confidence. Greater clarity is also needed on some of the new or changed measures and further steps should be taken on others. One key example of this is the relationship between the national planning framework, NPF, regional spatial and economic strategies and development plans, and how we estimate housing need and ensure sufficient land is available for new housing. Demographic forecasting is a useful tool in trying to estimate housing need. However, we know the population projections on which the housing targets are based need to be revised based on census 2022. This needs to happen with greater urgency. The updating of population and housing figures in the NPF should be undertaken ahead of an overall NPF review given the census results and the significant underestimation of housing needs in current strategies. Zoned housing, based on out-of-date population data and unrealistic assumptions of housing delivery timescales, will only ensure that government housing targets and Ireland’s housing needs will not be met.

The act of zoning land for residential use does not mean it is viable to build homes there, and this is the reason that we are left with some zoned land that is not yet built on. Greater focus is needed on assessing where it is viable to build homes, and in what format and this is not a straightforward exercise.

Given the lead-in time from zoning to completion of housing units, the extension of the duration of a development plan to ten years is welcome as it will contribute to adequate housing supply. The down-zoning of residential land, or the inclusion of core strategy housing development limits, which has the same effect, is unhelpful. We also welcome the greater emphasis on discussion and consultation at the plan-making stage, as opposed to challenges specifically to planning permissions, and greater clarity on the hierarchy of guidelines.

With regard to An Bord Pleanála, the PII welcomes the proposal for timelines for planning decisions and the recent new appointments and committee resourcing to the board. It is essential that robust structures are put in place to ensure the stated timelines can be adhered to. There are many more detailed provisions on which we would want to comment, as there is not enough time for that in this opening statement, but we have included examples of these in the appendix submitted. We are happy to discuss our recommendations in more detail and look forward to engaging with the committee in the question-and-answer session later.